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Name: Data Classification Policy - Interim
Responsible Office: Information Technology

Applies to: (examples; Faculty,Staff, Students, etc)

Faculty , Staff , Students , Contractors_Vendors

Policy Overview:

Issued: 11-30-2018
Next Review Date: 12-05-2019
Frequency of Reviews: Annually

College Data is information generated by or for, owned by, or otherwise in the possession of STLCOP that is related to the College’s activities. College Data may exist in any format (i.e. electronic, paper) and includes, but is not limited to, all academic, administrative, and research data, as well as the computing infrastructure and program code that supports the business of STLCOP.

Applies to all active members of the College community, including faculty, students, staff, and affiliates, and to authorized visitors, guests, and others for whom College technology resources and network access are made available by the College.  This policy also applies to campus visitors who avail themselves of the College’s temporary visitor wireless network access, and to those who register their computers and other devices through Conference and Event Services programs or through other offices, for use of the campus network. 


Details:

In order to effectively secure College Data, we must have a vocabulary that we can use to describe the data and quantify the amount of protection required. This policy defines four categories into which all College Data can be divided:

  • Public
  • Internal
  • Confidential
  • Restricted Use

College Data that is classified as Public may be disclosed to any person regardless of their affiliation with the College. All other College Data is considered Sensitive Information and must be protected appropriately. This document provides definitions for and examples of each of the four categories. Other policies within the Data Protection Standards specify the security controls that are required for each category of data.

The various units and departments at the College have a multitude of types of documents and data. To the extent particular documents or data types are not explicitly addressed within this policy, each business unit or department should classify its data by considering the potential for harm to individuals or the College in the event of unintended disclosure, modification, or loss. The Departmental Security Administrator (defined in the Data Management Guide) may assist with the classification process and coordinate with the STLCOP Information Security Team to achieve consistency across the College. When classifying data, each department should weigh the risk created by an unintended disclosure, modification or loss against the need to encourage open discussion, improve efficiency and further the College’s goals of the creation and dissemination of knowledge. Departments should be particularly mindful to protect sensitive personal information, such as Social Security Numbers, drivers’ license numbers and financial account numbers, disclosure of which may create the risk of identity theft.

Some information could be classified differently at different times. For example, information that was once considered to be Confidential data may become Public data once it has been appropriately disclosed. Everyone with access to College Data should exercise good judgment in handling sensitive information and seek guidance from management as needed.

Scope

This classification scheme is to be applied to all College Data, both physical and electronic, throughout STLCOP. No data item is too small to be classified.

Procedures:

Public

Public data is information that may be disclosed to any person regardless of their affiliation with the College. The Public classification is not limited to data that is of public interest or intended to be distributed to the public; the classification applies to data that does not require any level of protection from disclosure. While it may be necessary to protect original (source) documents from unauthorized modification, Public data may be shared with a broad audience both within and outside the College community, and no steps need be taken to prevent its distribution.

Examples of Public data include press releases, directory information (not subject to a FERPA block), course catalogs, application and request forms, and other general information that is openly shared. The type of information a department would choose to post on its website is a good example of Public data.

Internal

Internal data is information that is potentially sensitive and is not intended to be shared with the public. Internal data generally should not be disclosed outside of the College without the permission of the person or group that created the data. It is the responsibility of the data owner to designate information as Internal where appropriate. If you have questions about whether information is Internal or how to treat internal data, you should talk to your dean or department head.

Examples of Internal data include: Some memos, correspondence, and meeting minutes; contact lists that contain information that is not publicly available; and procedural documentation that should remain private.

Confidential

Confidential data is information that, if made available to unauthorized parties, may adversely affect individuals or the business of STLCOP. This classification also includes data that the College is required to keep confidential, either by law (e.g., FERPA) or under a confidentiality agreement with a third party, such as a vendor. This information should be protected against unauthorized disclosure or modification. Confidential data should be used only when necessary for business purposes and should be protected both when it is in use and when it is being stored or transported.

Any unauthorized disclosure or loss of confidential data must be reported to the appropriate dean or department head. The dean or department head should determine whether to report the unauthorized disclosure or loss of confidential data to the IT Department Chief Information Security Officer (“CISO”).

Examples of Confidential data include:

  • Information covered by the Family Educational Rights and Privacy Act (FERPA), which requires the protection of records for current and former students. This includes pictures of students kept for official purposes.
  • Personally identifiable information entrusted to our care that is not Restricted Use data, such as information regarding applicants, alumni, donors, potential donors, or parents of current or former students.
  • The STLCOP ID Number, when stored with other identifiable information such as name or e-mail address.
  • Information covered by the Gramm-Leach-Bliley Act (GLB), which requires protection of certain financial records.
  • Individual employment information, including salary, merit increases, benefits and performance evaluations for current, former, and prospective employees.
  • Legally privileged information.
  • Information that is the subject of a confidentiality agreement.

Restricted Use

Restricted Use data includes any information that STLCOP has a contractual, legal, or regulatory obligation to safeguard in the most stringent manner. In some cases, unauthorized disclosure or loss of this data would require the College to notify the affected individual and state or federal authorities. In some cases, modification of the data would require informing the affected individual.

The College’s obligations will depend on the particular data and the relevant contract or laws. The Minimum Security Standards Policy sets a baseline for all Restricted Use data.  Systems and processes protecting the following types of data need to meet that baseline:

  • Personally identifiable health information that is not subject to HIPAA but used in research, such as Human Subjects Data, where so designated by the Institutional Review Board (IRB).
  • Personally Identifiable Information (PII) such as an individual’s name plus the individual’s Social Security Number, driver’s license number, or a financial account number.
  • Unencrypted data used to authenticate or authorize individuals to use electronic resources, such as passwords, keys, and other electronic tokens.
  • “Criminal Background Data” that might be collected as part of an application form or a background check.
  • DEA Background checks that may be collected as part of the user onboarding process.
  • Vaccination records for school registration purposes.

More stringent requirements exist for some types of Restricted Use data.  Individuals working with the following types of data must follow the College policies governing those types of data and consult with the Information Security Team to ensure they meet all of the requirements of their data type:

  • Protected Health Information (PHI) subject to the Health Insurance Portability and Accountability Act (HIPAA), which sets standards for protection of medical records and patient data. See the HIPAA Policy for details.
  • Financial account numbers covered by the Payment Card Industry Data Security Standard (PCI-DSS), which controls how credit card information is accepted, used, and stored.
  • Controlled Unclassified Information required to be compliant with NIST 800.171
  • Data controlled by U.S. Export Control Law such as the International Traffic in Arms Regulations (ITAR) or Export Administration Regulations (EAR). ITAR and EAR have additional requirements.
  • U.S. Government Classified Data

Restricted Use data should be used only when no alternative exists and must be carefully protected. Any unauthorized disclosure, unauthorized modification, or loss of Restricted Use data must be reported to the STLCOP Security Incident Response Team. Please see the Security Incident Response Policy

Resolving Conflicts between this Guideline and Other Regulations

Some data may be subject to specific protection requirements under a contract or grant, or according to a law or regulation not described here. In those circumstances, the most restrictive protection requirements should apply. If you have questions, please contact Information Security.

Important

Failure to comply with the Data Protection Standards may result in harm to individuals, organizations or STLCOP. The unauthorized or unacceptable use of College Data, including the failure to comply with these standards, constitutes a violation of College policy and may subject the User to revocation of the privilege to use College Data or Information Technology or disciplinary action, up to and including termination of employment.

 

Resources:

Data Management Guide
Security Incident Response Policy
Health Insurance Portability and Accountability Act (HIPAA) Policy

Policy Contacts:

Name

Contact Information

Todd Finoch, Assistant Vice President, I.T. & Chief Information Officer

Todd.Finoch@stlcop.edu, 314-446-8402

Eric Knoll, Vice President, Operations

Eric.Knoll@stlcop.edu, 314-446-8375

Supplemental Information:

None